Privacy Ref Blog

Happy Data Privacy Day

Data Privacy Day (DPD), held every January 28 and coordinated by the National Cyber Security Alliance (NCSA), is an international effort highlighting “Respecting Privacy, Safeguarding Data and Enabling Trust.” DPD provides an opportunity for you to re-enforce these themes within your organization to improve privacy awareness. The result is that you will increase your customer’s trust in your organization while reducing costs and liabilities due to human error while handling personal information. [Disclosure: My company, Privacy Ref Inc., is a sponsor of Data Privacy Day.]

Having a comprehensive privacy program in place is essential for meeting the expectations of your customers, employees, and regulators. Many programs provide formal training about their policies and procedures on an annual basis. This usually involves classroom sessions or computer-based-training.

When speaking with my clients I find that privacy training is generally part of a long list of annually required compliance training. Team members outside the privacy office often find that the privacy topics become a blur; the privacy messages get lost in the ethics, security, human resources and other compliance topics that get covered.

For a privacy officer, the probability that staff members do not remember privacy messages will keep them up at night. Instituting an awareness program will help get your privacy officer back to sleep.

Awareness keeps privacy “top of mind”

Where a training program focuses on formal classes, an awareness program provides an eclectic approach to re-enforce your privacy messages on an informal basis. Supplementing your formal training with an on-going awareness program will keep privacy messages well-defined for your team between formal training sessions.

An awareness program should take advantage of existing communication vehicles. Company newsletters, a privacy intranet site and emails are where your team is accustomed to finding up-to-date information. You can use these vehicles to periodically remind the team about their privacy obligations.

For example, your compliance testing may show that personal information is being transferred via email in clear text in violation of your privacy policy. An article in the company newsletter or an email reminder discussing why encrypting emails containing sensitive information is important, accompanied by an explanation on how to encrypt an email, is a simple awareness step to addressing the situation.

An awareness program may also include periodic discussions, lunch and learns, posters or guest speakers. I think of these privacy-specific vehicles as events, which simply by announcing them, can create a buzz (yes, even the posters).

Ultimately an awareness program is marketing privacy within your organization. While the awareness program will be effective by re-enforcing your privacy messages for individual team members, it will be a booming success if you can start conversations about privacy.

Be creative

One organization worked with their cafeteria staff to change their menu for DPD. Firewall Hot Wings, Encrypted Eggplant Parmigiana and Hacker Hot Dogs appeared on the menu. The buzz around the tables during lunch didn’t focus on the company’s privacy program, but about the privacy incidents the employees’ experienced in their own lives. The goal of making privacy “top of mind” was met.

I’ve also seen a table set up in an organization’s lobby where employees can play “the privacy game.” All they need to do is identify which items on the table contain personal information, provide the classification for the information and explain how to protect it. Winners get a small trinket similar to what you might get at a trade show.

The game always draws a crowd. The crowd always expands when a C-level executive shows up to play. The executive participation tacitly endorses your program and adds to the privacy conversation.

Back to Data Privacy Day

DTD is January 28 every year. If you haven’t taken advantage of the date to run an awareness event this year, you don’t have to wait until next year. Pick a date in the next few weeks and declare DPD for your organization.

Hold a privacy event. Be creative. Have some fun. Maybe next year you can sync up with the international celebration.

Bob Siegel, the founder and President of Privacy Ref, Inc., has extensive professional experience in the development and improvement of privacy policies and procedures, the definition of performance metrics to evaluate privacy maturity, and the evaluation of compliance. He utilizes a combination of alignment, adaptability, and accountability strategies to guide organizations in achieving their privacy goals.

He is a Fellow of Information Privacy (FIP) and a Certified Information Privacy Professional, awarded from the International Association of Privacy Professionals, with concentrations in U.S. private-sector law (CIPP/US), US public sector law (CIPP/G), European law (CIPP/E), and Canadian law (CIPP/C). He is also a Certified Information Privacy Manager (CIPM) and Privacy Technologist (CIPT).

Siegel is a member of the IAPP faculty, has served on the Certification Advisory Board for the CIPM program the Publications Advisory Board.

On our last webinar (as of this writing) I discussed how a company can handle data subject’s rights requests under GDPR. Many of these requests are going to require attention, such as those ‘right to be forgotten’ requests. Others may seem daunting but can be handled easily and may not require any direct participation from your end.
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